Discuss the following statements : Company A and Company B who has entered into Advance Pricing Agreement (APA) and eligible for rollback provisions merged to form Company AB. Is the Company AB eligible for rollback prov

The agreement of APA is between the Board and a taxpayer person. The principle to be followed is that the person who makes the APA application alone would be entitled to enter into the agreement and be entitled for the rollback provisions in respect of international transactions undertaken by it in rollback year. Since Company A and B were the APA Applicants and not the new Company AB formed as a result of merger, Company AB would not be eligible for the rollback provisions.